## Facts

- In 1991, Montez Stovall, then a juvenile, fatally shot two men.
- In 1992, he pleaded guilty in two separate cases to second-degree murder and felony-firearm in exchange for dismissal of first-degree murder charges.
- The plea agreement called for life imprisonment with the possibility of parole for each second-degree murder conviction, consecutive to mandatory two-year felony-firearm terms.
- In 1993, Stovall moved to withdraw his plea; the trial court denied the motion, the Court of Appeals affirmed, and the Michigan Supreme Court denied leave.
- Stovall later filed multiple unsuccessful postconviction motions.
- In 2017, Stovall filed a successive motion for relief from judgment asserting (1) the plea was illusory and (2) his parolable life sentences, imposed for juvenile conduct, were unconstitutional because they did not provide a meaningful opportunity for release.
- The trial court denied relief; the Court of Appeals affirmed on remand; the Michigan Supreme Court granted leave to appeal.

## Issues

1. Whether a successive motion for relief from judgment was barred by MCR 6.502(G)(2), or whether it could proceed because it was based on a retroactive change in law.
2. Whether life imprisonment with the possibility of parole for a defendant who committed second-degree murder as a juvenile violates the Michigan Constitution’s prohibition on “cruel or unusual punishment,” Const. 1963, art. 1, § 16.
3. Whether the sentence violated the Eighth Amendment under juvenile-sentencing precedents (raised but not necessary to the dispositive holding).

## Decision

- The Michigan Supreme Court reversed the Court of Appeals, vacated Stovall’s parolable life sentences, and remanded for further proceedings.
- The Court held the successive motion was not barred by MCR 6.502(G)(2) because a retroactive change in law need only provide a foundation for the claim to pass the procedural gate.
- The Court held that parolable life for juvenile second-degree murder is “cruel or unusual punishment” under the Michigan Constitution and is unconstitutional.
- The Court’s disposition rested on state constitutional grounds; federal Eighth Amendment resolution was not required.

## Legal Principles

- Under MCR 6.502(G)(2), a successive motion may proceed when premised on a retroactive change in law that supplies a foundation for the claim; the rule should not be read to collapse the procedural threshold into the merits standards of MCR 6.508(D).
- Michigan’s “cruel or unusual punishment” clause (Const. 1963, art. 1, § 16) is an independent limitation that can provide broader protection than the federal “cruel and unusual punishments” clause.
- Proportionality review under the Lorentzen/Bullock framework considers: (1) offense gravity versus penalty severity, (2) punishment in other jurisdictions, (3) punishment for other Michigan offenses, and (4) the goal of rehabilitation.
- A parolable life sentence imposed on a juvenile for second-degree murder is disproportionate under the state constitution given (a) its severity and indeterminacy, (b) comparative disparities with current juvenile first-degree murder sentencing practices, (c) broader jurisdictional trends toward less severe juvenile punishment, and (d) the sentence’s tension with rehabilitation and a realistic opportunity for release.

## Conclusion

The Michigan Supreme Court held that life imprisonment with the possibility of parole for juvenile second-degree murder violates the Michigan Constitution’s ban on cruel or unusual punishment, and it permitted the defendant’s successive postconviction motion to proceed based on a retroactive change in law before vacating the sentence and remanding.


People v. Stovall, 510 Mich. 301, 987 N.W.2d 85 (Mich. 2022)